Windle and Monyn (Child support)

The matter of *Windle and Monyn* concerned a dispute over the percentage of care arrangements for a child, brought before the court for review. The existing percentage of care determinations had been revoked, and new determinations made, following non-compliance with court orders. The central issue was whether these changes reflected a genuine alteration in the likely pattern of care.

The court was required to determine whether the parent with reduced care had taken reasonable action to maintain the existing care arrangements, and whether an interim period should have been considered when assessing the change in care. The court also considered the validity of the revoked and new percentage of care determinations in light of the circumstances.

The court found that the decision under review was flawed. It reasoned that the Registrar had failed to adequately consider whether reasonable action had been taken by the parent whose care percentage had decreased, and had not properly accounted for any interim period during which care arrangements might have been in flux. Consequently, the court set aside the decision and remitted the matter to the Child Support Registrar for reconsideration.